Hogan Lovells US LLP
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www.hoganlovells.com
December 19, 2011
VIA EDGAR
Adam F. Turk, Attorney-Advisor
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
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Re:
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Apartment Investment and Management Company |
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AIMCO Properties, L.P. |
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Registration Statement on Form S-4 |
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Filed July 28, 2011 |
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File No.: 333-175847
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Dear Mr. Turk:
Apartment Investment and Management Company (Aimco) and AIMCO Properties, L.P.
(Aimco OP) are today filing an amendment to the Registration Statement (File No.
333-175847) on Form S-4 (the NPI 4 Form S-4) referenced above. The NPI 4 Form S-4
relates to the merger of National Property Investors 4.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the NPI 4 Form
S-4 are similar in nature to those that were previously made by Aimco and Aimco OP in the
amendments to three Registration Statements on Form S-4 (File Nos. 333-175843, 333-175848 and
333-175853), filed with the Securities and Exchange Commission on November 15, 2011 (the Prior
Filings). The changes made to the NPI 4 Form S-4 (including opinions filed as exhibits)
respond to the Staffs comments in the same manner as the Prior Filings.
* * * *
If you have any questions regarding the foregoing, please contact Robert Mintz at (303)
899-7399.